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of <h1>Article 4 DTAA: Defines Tax Residency Criteria, Resolves Dual Residency via Permanent Home or Mutual Agreement</h1> Article 4 of the Double Tax Avoidance Agreement (DTAA) defines a 'resident of a Contracting State' as any person liable to tax in that state due to domicile, residence, citizenship, management, incorporation, or similar criteria. It excludes those taxed solely on income from sources within the state. For dual residents, residency is determined by the location of a permanent home, center of vital interests, habitual abode, or nationality, with unresolved cases settled by mutual agreement. Companies resident in both states are generally outside the Convention's scope, except for specific articles. Non-individual, non-company dual residents are also resolved by mutual agreement.
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